Guide to The EU Accessibility Act 2025

Is your business accessible? UK businesses trading in the EU may need to review the accessibility of products and services to ensure compliance with the EU Accessibility Act (EAA). which comes into effect in June 2025.

In September 2024, we produced a guide for Making Your Website Accessible because, although not technically a legal requirement, failing to provide equal access could be viewed as negligent or even discriminatory. However, accessibility is not only important for websites and inclusivity isn’t a marketing term - it’s about providing access for persons with disabilities and older people to a wide range of products and services.

Hence, the European Union has established the Accessibility Act to provide a set of common accessibility standards throughout the EU internal market. The question is, will this impact those not in the EU, such as the UK?

Do UK Businesses Need To Comply With The EU Accessibility Act?

This depends on whether the business makes its services or products available to consumers in EU member states. If so, then yes, they will need to be compliant with the EU Accessibility Act.

For businesses that don’t market specifically to EU countries but may still provide products or services to them, they will need to decide whether to comply with the new legislation or to restrict who they sell to. 

Those who do not, or do not intend to sell in the EU, but have a website that can be accessed globally, should consider the following -

• Geo-blocking: Using IP-based geo-location to block access from EU countries.

• Payment Blocking: Disallow transactions in EU currencies or from cards with EU-based billing addresses.

• Restrict Shipping: Product-based businesses may not ship to EU locations.

• Legal Clarity: Confirm in your legal documents - such as Terms of Service - that the product or service is not intended for use in the EU.

• Localise Marketing: Don’t advertise to consumers in the EU.

• Review Distribution Channel: Check that distributors, such as publishers, ecommerce sites and content platforms, are restricting product/service availability by region.

Other Exemptions

Organisations with fewer than 10 employees or an annual turnover of under 2 million Euros are exempt from legally having to comply with the EU Accessibility Act. 

There is also the clause of disproportionate burden, which is a little more complex. This basically omits smaller companies or those with financial constraints where implementing changes required to be compliant would put considerable pressure on them, potentially harming their business or putting it at risk. However, use of this clause rests on being able to justify that the company lacks the resources, finances or ability to comply. Therefore, I urge you to research this in far more detail and seek legal advice, if you believe this might apply to you.Lastly, there are exemptions for where implementing these changes to a product or service would impact its functionality or render its use/purpose redundant. Again, this is more complex so you’ll need to explore this further. Don’t assume you’ll qualify for this exemption without scrutinising the criteria.

Ultimately, it’s important not to let the EU Accessibility Act put you off operating in EU states without understanding the requirements for doing so. After all, you may find you’re already compliant. So, let’s go through some of the key parts of the legislation -

Key Parts of the EU Accessibility Act

The purpose of the EU Accessibility Act (which we’ll now refer to as the EAA) is to make products and services more accessible to those with disabilities or other potential impairments, including those impacted by age, pregnancy and neurodivergence.  Above all, it is legislation intended to help companies navigate fulfilling consumer requirements more inclusively. So, it’s important not to view it as a barrier but rather as a guide for operating in a way that can benefit both the public and the organisation.In this short guide, we won’t be able to cover everything in detail, but here is the overview and key parts of the legislation you should be aware of if you are operating in the EU or intend to do so - 

Products and Services

The scope for products and services that must comply with this legislation is wide but may apply to;

• ATMs, ticket machines, self-service kiosks

• Electronic devices

• Transport services

• Computers, systems and software

• Financial services

• E-commerce platforms

• Media services

• E-book readers

Companies will need to assess whether these products and services can be used by those with specific accessibility needs. You should ensure, in particular, that you have -Made visual and audio output accessible: Users should not be reliant upon a single form of information, such as hearing for those with hearing impairments or vision for those with sight loss. Businesses might use braille, text-to-speech functions, subtitles, alt descriptions (for images), etc. to break down barriers in accessing their products/systems/services, so there are multiple ways to access information.

Ensured inclusive operational use: The physical operation of your product should be optimised in a way that allows for persons with disabilities or impairments to navigate and complete tasks independently. For example, wheelchair users should be able to see and reach buttons/touch screens, and product use should not require fine motor skills. Navigation must be clear and logical, and digital products and systems should also avoid time-out functions (or enable them to be disabled). 

Machines or tech should, where possible, be compatible with screen-readers and other devices that enable better access for some users. They should be able to adjust settings, such as font size, and keyboard-only navigation should be optimised. Provided accessible instructions and packaging: The EAA requires that all consumer-facing information related to a product, including user manuals, safety instructions, packaging labels, and warranty information, must be accessible to people with disabilities. This may require different versions of essential information to be made available.

Furthermore, you should ensure that products are compatible with commonly used assistive technologies, such as screen readers and voice recognition tools. The good news is that you don’t necessarily have to build these products yourself; many market-leading assistance tools can often be integrated into existing software.

Accessible Services

Much of the above also applies to customer services and service-based businesses. Companies must ensure their contracts, billing information, customer support and essential information such as ordering, payment and terms are optimised for various accessibility needs. Communication support should also be provided through means such as text relay, captioning or sign language, and support chat should be compatible with assistance tools, such as screen readers.

Access to Products and Services

Channels of access will also need to comply with the EAA. This means websites must meet EN 301 549 standards of the Web Content Accessibility Guidelines (WCAG 2.1 AA).

Confused? Not to worry, we have produced a handy guide on Making Your Website Accessible, which will explain all requirements.

Mobile apps will also need to meet the same principles and must support screen readers, voice commands and scalable text. These should all be checked on different browsers and operating systems to ensure they are all compatible with the accessibility settings put in place.Other considerations include digital documents such as invoices and other digital materials provided to customers.

The Timeline For EU Accessibility Act Compliance

The EAA comes into force on June 28th 2019, but compliance must be met by June 28th 2025. This is the deadline by which you must ensure all new products and services comply. However, you have until June 28th 2030, to make all necessary changes to products and services available before June 2025. As this process may be lengthy and require some research and then testing before changes are implemented/installed, it would be wise to begin this as soon as possible. Besides, it’s important to remember that by making your business more accessible, you are not only meeting the needs of persons with disabilities and special requirements, but you are also opening your business up to a wider clientele, which will be beneficial in the long run. Not to mention that non-compliance can result in fines, your products being removed from the market and/or reputational damage.

Keeping Your Business Informed

Do you ever worry about missing out on key legislation, such as the EAA, that could affect your business? Keep up to date with all commercial legal matters and considerations by subscribing to my monthly newsletter or following me on LinkedIn.